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4965 REVIEW GRANTED In a personal injury action, in which the plaintiff has private health care insurance, the negotiated rate differential between the billed amount and the actual required payment is a benefit within the meaning of the collateral source rule, and thus the plaintiff may recover the differential as part of economic damages for the past medical expenses she incurred for care and treatment of her injuries. CitationHOWELL v HAMILTON MEATS & PROVISIONS, INC. (Keeping the Discount) 179 CA4 686 (rev grtd) [See: CivC 3333; Helfend v. So Cal Rapid Transit 2 C3 1 (1970); Hanif v. Housing Auth 200 CA3 635 (1988); Nishihama v. City and County of San Francisco 93 CA4 298]
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